T1
Also known as: T1 document, external Union transit
A T1 is the declaration for customs transit of goods that have not yet been cleared, so they may travel through the EU under suspension of duties. The declaration runs through NCTS and requires a guarantee for the potential customs debt.
When do you need a T1?
You use a T1 when non-Union goods have to move inside the EU before the duties have been paid. Think of a container that arrives in Rotterdam and is cleared in Germany, or goods that go from a warehouse to another member state. As long as the goods are on T1, no import duties and no VAT have been paid. The term is both a status (under suspension) and a document (the transit declaration with which that status travels). Without a T1 the goods would have to be cleared at the place of entry. The procedure makes it possible to do that later and elsewhere. That is why ports, inland terminals and warehouses use the T1 as the standard link in the chain: the container may leave the terminal without the IMA already being ready. A T1 is also needed when goods go from temporary storage to a warehouse or another member state, or when a shipment after re-export still has a road leg. The document can be closed while the goods keep T1 status, for example after placement in a customs warehouse.
How does a T1 work in NCTS?
The declarant files the declaration at the office of departure. In the Netherlands that runs through DVA, the Dutch system for NCTS, with a departure part and an arrival part. After acceptance the shipment gets an MRN and the accompanying document is printed or given digitally. Without that MRN the container does not leave the terminal, even if the rest of the file is in order. On arrival the consignee presents the goods at the office of destination. The office of destination reports the arrival back to the office of departure. Only after that return message is the procedure discharged and the guarantee freed again. Until then the amount stays reserved on the comprehensive guarantee. With an authorised consignee authorisation the arrival may be reported at the own location, without presenting the goods at a customs office. For volume that is the difference between an extra trip and a message in the system. Discharge stays the same: without the return message the T1 stays open.
What happens if a T1 is not discharged?
If the return message stays out, Customs starts an enquiry procedure. The declarant must then show where the goods went, for example with alternative proof of presentation: an IMA, an STO, an arrival confirmation from the office of destination in another member state. If that fails, a customs debt arises and the guarantee is called on. At high values that quickly runs into tens of thousands of euro, which is why open T1s should be watched daily. Looking weekly is too late: the time limit set by the office of departure is usually a few days to a week. Exceeding the time limit leads to an enquiry, even if the goods later still arrive. A late discharge is therefore not the same as no discharge, but it does produce work and it keeps guarantee headroom occupied. Watch the expiry date, not only the question of whether the T1 ever closes.
Who may open a T1 and which guarantee is needed?
The holder of the procedure opens the T1 and is the party responsible for discharge. That can be the forwarder, the carrier or the consignee, as long as that party has given a guarantee that covers the potential customs debt. Without a guarantee the declaration is not accepted in NCTS. The guarantee is usually a comprehensive guarantee: a bank guarantee or an insurance that covers a maximum amount for all running shipments together. That amount is calculated on the average outstanding risk over a period. If the number of open T1s rises, the guarantee fills up and new declarations are refused. That is the practical reason to watch discharge daily and not weekly. With an authorised consignor authorisation the holder may release the shipment themselves without presenting it at a customs office. That saves a trip and a waiting time, and for companies with daily volume it is the difference between viable and not. The authorisation hangs on the holder's EORI number, not on the driver.
What actually goes on a T1?
The declaration contains the office of departure and of destination, the holder of the procedure, the carrier, the vehicle registration or the container numbers, the goods description with the goods code, the weight and the value, and the guarantee reference. If one of those elements is missing, the declaration comes back before there is an MRN. The goods code for customs transit only needs to be six digits, because no tariff is set. The description must still be specific enough that the goods are recognisable at a control. Descriptions such as goods or parts are a standard reason for a control order. A container with twenty article lines may be summarised on the T1, as long as Customs can recognise the cargo from it. The route does not have to be fixed, unless Customs prescribes a binding itinerary. That happens for goods with a high fraud risk, such as cigarettes and alcohol. In those cases a deviation from the route is itself a reason for enquiry, even if the goods later arrive in order.
How do you watch open T1s?
Every working day a list of open MRNs, with expiry date, office of destination and remaining guarantee. A T1 that expires tomorrow should have an arrival notification or a query today, not only when Customs starts the enquiry. At volume that is not a spreadsheet someone updates at the end of the week. Link the T1 to the follow-up declaration. An IMA or STO that has been accepted discharges the T1 in principle automatically. If the T1 stays open while the IMA is there, the link between the two MRNs has not been made. That is one of the most common causes of an open T1 on a file that is substantively finished. Watch the guarantee headroom as well. A guarantee of a fixed amount covers a fixed number of open shipments. If a peak comes, NCTS refuses new T1s without the operation noticing that at the gate. The container then stands ready, the declaration does not go through, and the cause sits in ten T1s from last week that were never discharged.
How does a T1 sit in the declaration chain?
A T1 is rarely the beginning or the end. On arrival in a Dutch seaport it follows the summary declaration or the shipping line's temporary storage, and it precedes the IMA, the STO or the re-export. Each link refers to the previous one. A gap in that chain produces questions from Customs, and if a piece is missing a customs debt. At the terminal the MRN of the T1 is the number that is linked to the container number via Portbase. Without that link the terminal does not release the container. The T1 can be accepted on its merits, and the container stays until someone passes the MRN on. That is not a customs error, it is a chain error. On exit from a warehouse to another member state the T1 opens again, with the warehouse authorisation as the previous procedure. The chain then stays T1, warehouse, T1, IMA in the other country. Anyone who only looks at their own declaration does not see whether the previous link has been discharged. Watch the chain, not the loose T1.